Elizabeth Hoppe v. Lewis University, 692 F.3d 833

Hoppe, a tenured philosophy professor at Lewis University, taught aviation ethics with no formal aviation training or industry experience.
Brogan, newly appointed chair of the Aviation Department, removed Hoppe from aviation ethics in February 2009 for lacking qualifications and later for behavior during a FedEx trip.
Hoppe filed EEOC discrimination charges (2007) and retaliation charges (2007, 2009; also 2010) seeking disability accommodation for an adjustment disorder.
The university offered three office accommodations in 2008; Hoppe rejected all three and provided limited information about medical restrictions.
Hoppe moved offices in 2010 after a doctor’s letter but never moved in; she sued for discrimination, retaliation, and failure to accommodate; district court granted summary judgment for the university on all six claims.
The Seventh Circuit affirmed, concluding there was no triable issue on whether Hoppe could perform essential functions, that accommodation was reasonable, and that no causal link supported retaliation.

Issue	Plaintiff's Argument	Defendant's Argument	Held
ADA discrimination—essential functions and accommodation	Hoppe could perform essential functions; university failed to accommodate.	No evidence Hoppe could perform essential functions; university provided reasonable accommodations.	No genuine dispute on reasonableness; summary judgment affirmed on ADA claim.
Adequacy of interactive process and reasonableness of accommodation	University failed to engage in good faith interactive process.	University offered three accommodations and acted in good faith.	Accommodation was reasonable; district court proper on this point.
Retaliation—causal link between protected activity and removal	Temporal proximity and knowledge by decisionmakers show causation; pretext.	No evidence that Brogan or Ayers knew of protected activity; no causal link.	No evidence of a causal link; summary judgment on retaliation upheld.
Final decisionmaker for removal from course	Dean Ayers was the ultimate decisionmaker.	Dean Ayers did not have veto power over course assignments.	Hoppe failed to prove Ayers was ultimate decisionmaker.
Pretext evidence for retaliation	Past positive evaluations and timing suggest pretext.	No evidence tying protected activity to removal; lack of direct causation.	No triable issue on pretext; not enough to defeat summary judgment.

Steffes v. Stepan Co., 144 F.3d 1070 (7th Cir. 1998) (interactive process and accommodation duty; failure to cooperate can lead to judgment for employer)
EEOC v. Sears, Roebuck & Co., 417 F.3d 789 (7th Cir. 2005) (interactive process lacks adequate medical detail can undermine accommodation)
Lalvani v. Cook Cnty., 269 F.3d 785 (7th Cir. 2001) (temporal proximity requires close sequence between protected activity and action)
Fortier v. Ameritech Mobile Commc’ns, Inc., 161 F.3d 1106 (7th Cir. 1998) (prior employment history has limited utility in evaluating performance at termination)
Miller v. Illinois Dept. of Transportation, 643 F.3d 190 (7th Cir. 2011) (evidence of pretext may come from shifting explanations)
Bernuzzi v. Bd. of Educ. of City of Chicago, 647 F.3d 652 (7th Cir. 2011) (direct method proof requires causation between protected activity and adverse action)